Michigan Dept. of State Police v. Sitz Case Brief

Michigan Dept. of State Police v. Sitz, 496 U.S. 444 (1990)

FACTS: In early 1986, the Michigan State Police established a sobriety checkpoint. A task force, appointed by the police director, created guidelines concerning checkpoint operations, site selection and publicity. Under those guidelines, all vehicles passing through a checkpoint would be stopped and the driver checked for intoxication. If the officer detected such signs, the motorist would be pulled out of the traffic flow and further examined, and if appropriate, arrested. All other drivers would be allowed to continue.

On the first day of the first checkpoint, in Saginaw County, 126 vehicles passed through the checkpoint in 75 minutes, with the average delay being 25 seconds. Two drivers were further held for field sobriety testing, and one of the two was arrested. (A third vehicle drove through the checkpoint without stopping, and was later stopped and arrested for DUI.)

The checkpoints were suspended pursuant to an injunction filed in another county.

Following a hearing, the trial court found the checkpoints violated the Fourth Amendment. The Michigan Court of Appeals affirmed that decision. The state appealed.

ISSUE: Is a brief stop of a motorist to check for drunk driving unlawful?

HOLDING: No

DISCUSSION: The Michigan courts relied upon language in previous Supreme Court cases to perform a balancing test, between the rights of the motorists and the needs of the State to curb drunken driving. However, while the Court agreed that the stops were seizures, it determined such stops were reasonable, given the limited intrusion on law-abiding citizens and the tremendous problem with drunken driving in the United States.